Community First Choice Montana: How the CFC Program Pays for In-Home Care

What Community First Choice Actually Covers

Community First Choice (CFC) is a Medicaid state plan option under Section 1915(k) that funds personal care services for seniors and adults with disabilities who need help with daily activities but want to stay in their own homes. Montana's version is administered by DPHHS through the Senior and Long-Term Care Division.

The program covers personal care assistance with activities of daily living — bathing, dressing, transferring, toileting, eating — along with instrumental activities like meal preparation and medication reminders. It also funds personal emergency response systems (PERS) and transportation to medical appointments.

The distinction that matters: CFC is a state plan option, not a waiver. That means it operates without the enrollment caps that create waiting lists on the Big Sky Waiver. If you meet the eligibility criteria, you can access services without sitting on a queue.

Eligibility Requirements

To qualify for CFC, a person must meet three criteria simultaneously:

Financial eligibility. The same Medicaid thresholds apply — countable assets under $2,000 for a single applicant, income handled through Montana's medically needy spend-down pathway (no hard income cap). If your parent already qualifies for Medicaid long-term care, they qualify financially for CFC.

Functional limitation. The applicant must need assistance with at least one activity of daily living or require health-related tasks that can be performed by a personal care attendant rather than a licensed nurse.

Nursing home level of care. Mountain Pacific Quality Health (MPQH) must certify that the person would otherwise require nursing facility placement. This is the same clinical screening used for the Big Sky Waiver and institutional Medicaid.

The Paid Family Caregiver Option

This is where CFC becomes especially relevant for Montana families. Under ARM 37.40.1002, family members — including spouses — can be hired and paid as personal care attendants through the Self-Directed Community First Choice Services framework.

Two conditions authorize paying a legally responsible relative:

The extraordinary care standard requires DPHHS to verify through a functional assessment that the care needed exceeds what is normally expected in that family relationship. Routine household tasks alone may not meet the standard. Daily assistance with bathing, transfers, or wound care may qualify only if DPHHS's assessment finds that the care exceeds ordinary family care.

The geographic isolation exception applies when the person lives in a remote area where non-family care providers simply are not available — a common reality across rural Montana.

All personal care services must be delivered through an enrolled Medicaid provider agency that handles payroll, tax withholding, and W-2 issuance. The consumer or their representative approves timesheets, and all services are tracked through electronic visit verification (EVV).

CFC vs. the Big Sky Waiver

Both programs serve people who need nursing-facility-level care but want to remain at home. The practical differences:

The Big Sky Waiver covers a broader range of services — adult day care, respite, home modifications, and assisted living placement. CFC is limited to in-home services, including personal care, PERS, and transportation.

The Big Sky Waiver operates with capped enrollment and a priority-scored waiting list (Form SLTC-146). The research reports an average of 354 people waiting for waiver slots in SFY 2024. CFC has no such cap.

Some families use CFC as an immediate bridge while waiting for a Big Sky Waiver slot that would unlock additional services. The two programs can complement each other, but their services and eligibility rules differ; confirm with DPHHS how they coordinate in an individual plan.

How to Apply

CFC enrollment starts with a Medicaid application. Submit through apply.mt.gov, call 1-888-706-1535, or visit your regional Office of Public Assistance. Once Medicaid eligibility is established, request a Community First Choice referral through the DPHHS Senior and Long-Term Care Division.

MPQH will schedule a clinical assessment to determine nursing facility level of care. If approved, a service plan is developed that specifies the type and hours of personal care authorized.

The Medicaid financial determination has a 45-day standard processing window. Total time to active services also depends on clinical scheduling and the service-plan steps.

Making the Decision

CFC works best for families where a reliable caregiver (often a family member) is available and the person's care needs center on personal assistance rather than skilled nursing. For families in rural counties where home health agencies have limited reach, the paid caregiver option can be the difference between staying home and facility placement.

If your parent needs a broader service package — respite care, adult day services, home modifications, or assisted living coverage — the Big Sky Waiver is the more comprehensive program, though the waiting list adds uncertainty to the timeline.

For a complete breakdown of Montana's Medicaid long-term care pathways, eligibility thresholds, and asset protection strategies, the Montana Medicaid Long-Term Care & Asset Protection Guide walks through each option with step-by-step worksheets.

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